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Name: Yarborough v. Alvarado
Case #: 02-1684
Court: US Supreme Court
District USSup
Opinion Date: 06/01/2004

A state court finding that a defendant was not in custody for Miranda purposes did not involve an unreasonable application of clearly established federal law. The Ninth Circuit had found that the state court erred in failing to consider a defendant’s young age in determining whether a reasonable person would have believed that he was in custody at the time of questioning. The Supreme Court reversed, finding that clearly-established federal case law outlined an objective test for determining whether a suspect was in custody for Miranda purposes, and that objective test did not include consideration of the suspect’s age. The fact that a person’s age is considered under other analogous tests did not render the state court action unreasonable for purposes of federal habeas review.